Re: THE REQUEST OF SHELL WESTERN ) Area Injection Order No. 9
E & P INC for an Area )
Injection Order for the ) Central Portion of
portion of the Middle Ground ) Middle Ground Shoal Field
Shoal Field developed by )
"A" and "C" Platforms )
September 12, 1986

IT APPEARING THAT:

1. Shell Western E & P Inc. (SWEPI) requested the Alaska Oil and Gas Conservation Commission to issue an Area Injection Order permitting the underground injection of fluids within a portion of the Middle Ground Shoal Field for purposes of enhanced hydrocarbon recovery and fluid disposal.

2. Notice of an opportunity for a public hearing on September 26, 1986, was published in the Anchorage Daily News on August 27, 1986.

3. Neither a protest nor a request for a public hearing was timely filed. Accordingly the Commission will, in its discretion, issue an order without a public hearing.

FINDINGS:

1. An order permitting the underground injection of fluids on an area basis, rather than for each injection well individually, provides for efficiencies in the administration and surveillance of underground fluid injection operations. 20 AAC 25.460 provides the Commission with the authority to issue an order governing underground injection operations on an area basis.

2. The portion of the Middle Ground Shoal Field developed by SWEPI's platforms "A" and "C" constitutes a compact "project area" which can readily be described by governmental subdivisions. SWEPI is the sole operator of this Project Area.

3. The Project Area encompasses the approximate central one-half (1/2) of the Middle Ground Shoal Field. The Project Area includes all existing injection wells and injection well sites planned for enhanced recovery of oil from that portion of the MGS A, B, C, D, E, F, and G Oil Pools. The Project Area also includes all well sites planned for disposal by injection into shallower Tertiary strata of oil field waste fluids which may develop from the operation of this portion of the field.

4. The portion of aquifers beneath Cook Inlet described by a 1/4 mile area beyond and lying directly below the Middle Ground Shoal Field are exempted for Class II injection activities by 40 CFR 147.102(b)(2)(B) and 20 AAC 25.440(c).

5. Less stringent requirements for well construction, operation, monitoring, and reporting of injection operations may be more appropriate than would be required when injection occurs into, through or above portions of aquifers not exempted.

6. The vertical limits of injection strata and confining formations may be defined in the Pan American Petroleum Corporation State 17595 well No. 4 and SWEPI well No. A-42-11.

7. The strata into which fluids are to be injected will accept fluids at injection pressures which are less than the fracture pressure of the injection strata and their confining formations.

8. Statewide regulations and conservation orders govern field operations except as modified by this order.

9. To ensure that fluids injected are confined to injection strata, the mechanical integrity of injection wells should be demonstrated periodically and monitored routinely for disclosure of possible abnormalities in operating conditions.

10. Injection wells existing on the date of this order were constructed and completed in accordance with regulations which conform to the requirement of 20 AAC 25.412.

NOW, THEREFORE, IT IS ORDERED THAT the rules hereinafter set forth govern Class II underground injection operations in the following described area referred to in this order as the affected area:

SEWARD MERIDIAN

T8N

R13W

Section 1: all.

Section 2: E1/2.

Section 11: SW1/4 and E1/2.

Section 12: SW1/4 and N1/2.

Section 13: W1/2.

Section 14: all.

Section 22: SE1/4.

Section 23: all.

Section 24: W1/2.

Section 25: W1/2.

Section 26: all.

Section 27: E1/2.

Rule 1 Authorized Injection Strata for Enhanced Recovery

Within the affected area, non-hazardous fluids may be injected for purposes of pressure maintenance and enhanced oil recovery into strata defined as those strata which correlate with the strata found in the Pan American Petroleum Corporation State 17595 well No. 4 between the measured depths of 5,300 feet and 9,215 feet.

Rule 2 Authorized Injection Strata for Disposal

Within the affected area, non-hazardous oil field fluids may be injected for the purpose of fluid disposal into strata defined as those strata which correlate with the strata found in the SWEPI well No. A-42-11 in the measured depth intervals of 3134 feet to 3480 feet and 4680 feet to 5283 feet.

Rule 3 Fluid Injection Wells

The underground injection of fluids must be: 1) through a new well that has been permitted for drilling as a service well for injection in conformance with 20 AAC 25.005; 2) through an existing well that has been approved for conversion to a service well for injection in conformance with 20 AAC 25.280; or 3) through a well that existed as a service well for injection purposes on the date of this order.

Rule 4 Monitoring the Tubing/Casing Annulus Pressures

The tubing/casing annulus pressure of each injection well must be checked weekly to ensure there is no leakage and that it does not exceed a pressure that will subject the casing to a hoop stress greater than 70% of the casing's minimum yield strength.

Rule 5 Reporting the Tubing/Casing Annulus Pressure Variations

Tubing/casing annulus pressure variations between consecutive observations need not be reported to the Commission.

Rule 6 Demonstration of Tubing/Casing Annulus Mechanical Integrity

A schedule must be developed and coordinated with the Commission which ensures that the tubing/casing annulus for each injection well is pressure tested prior to initiating injection and at least once every four years thereafter. A test surface pressure of 1500 psi or 0.25 psi/ft multiplied by the vertical depth of the packer, which ever is greater, but not to exceed a hoop stress greater than 70% of the casing's minimum yield strength, must be held for 30 minutes with no more than a 10 percent decline. The Commission must be notified at least 24 hours in advance to enable a representative to witness pressure tests.

Rule 7 Well Integrity Failure

Whenever operating pressure observations or pressure tests indicate pressure communication or leakage of any casing, tubing or packer, the operator must immediately cease injection, notify the Commission, and obtain approval for corrective action.

Rule 8 Plugging and Abandonment of Fluid Injection Wells

An injection well located within the affected area must not be plugged or abandoned unless approved by the Commission in accordance with 20 AAC 25.105.

Rule 9 Administrative Relief

Upon request, the Commission may administratively amend any rule stated above as long as the operator demonstrates to the Commission's satisfaction that sound engineering practices are maintained and the amendment will not result in an increased risk of fluid movement into an underground source of drinking water.